In a landmark decision, the Supreme Court of India recently quashed a rape case, emphasizing the importance of distinguishing between consensual relationships and criminal acts. The case, Rajnish Singh Soni v. State of Uttar Pradesh, revolved around a 16-year-long relationship that the complainant alleged was sustained under false promises of marriage.
Background of the Case
The complainant, a highly educated woman, claimed that in 2006, the accused initiated a sexual relationship with her at her residence, promising marriage. She alleged that over the years, the accused coerced her into continuing the relationship by threatening to release intimate videos he had secretly recorded. The complainant further stated that she remained silent due to societal pressures but decided to file a First Information Report (FIR) in 2022 after discovering that the accused had married another woman. The charges included:
- Rape (Section 376 IPC)
- Extortion (Section 384 IPC)
- Voluntarily causing hurt (Section 323 IPC)
- Intentional insult (Section 504 IPC)
- Criminal intimidation (Section 506 IPC)
Supreme Court’s Analysis and Observations
A bench comprising Justices Vikram Nath and Sandeep Mehta examined the nuances of the case, focusing on the prolonged duration and nature of the relationship. The Court found it implausible that a well-educated woman would endure a non-consensual relationship for 16 years without taking action. The justices noted that the complainant had, on multiple occasions, portrayed herself as the accused’s wife, which contradicted her claims of deceit. Additionally, the complainant frequently traveled to meet the accused at his various postings, indicating a voluntary and consensual relationship.
The Court observed that the FIR was filed only after the complainant learned of the accused’s marriage to another woman, suggesting that the allegations arose from a soured relationship rather than criminal intent. The bench stated:
“No reasonable man would accept the version that the complainant allowed the accused to establish sexual relations with her over a period of 16 years purely under the misconception of marriage.”
Legal Precedents and Implications
This judgment aligns with previous Supreme Court rulings that emphasize the need to differentiate between consensual relationships and instances where consent is obtained through deceit. In Prashant v. State of NCT of Delhi (2024), the Court quashed an FIR filed under similar circumstances, highlighting that a consensual relationship that does not culminate in marriage cannot be construed as rape. The Court emphasized that:
“A mere breakup of a relationship between a consenting couple cannot result in initiation of criminal proceedings.”
Legal experts have welcomed the judgment, stating that it reinforces the principle that criminal law should not be weaponized to settle personal disputes. They argue that cases involving false allegations of rape could undermine the credibility of genuine victims and dilute the impact of stringent laws meant to protect women.
Conclusion
The Supreme Court’s decision in this case underscores the judiciary’s commitment to preventing the misuse of legal provisions in personal disputes. By carefully analyzing the context and nature of relationships, the Court aims to ensure that criminal proceedings are not initiated based on misconstrued notions of consent.
This judgment serves as a reminder of the importance of distinguishing between genuine cases of exploitation and situations where relationships deteriorate over time. As legal interpretations evolve, such verdicts play a crucial role in shaping societal understanding of consent and the boundaries of lawful conduct within personal relationships. They reinforce the principle that the law should not be weaponized to address grievances arising from failed relationships but should focus on genuine instances of criminal behavior.
Citations
- Law Chakra. Supreme Court Quashes Rape Case: Analysis of Rajnish Singh @ Soni v. State of Uttar Pradesh. Available at: https://lawchakra.in/supreme-court/analysis-supreme-court-quashes-rape-case/
- Verdictum. Prashant v. State of NCT of Delhi (2024). Available at: https://www.verdictum.in/court-updates/supreme-court/prashant-v-state-of-nct-of-delhi-2024-insc-879-consensual-relationship-not-criminal-if-it-doesnt-fructify-into-marriage-1558559
About Author
Kusha Mehta is a law student at Campus Law Centre, University of Delhi, with a background in economics. She has experience in legal research, writing, and analysis, Passionate about advocacy and policy, she has also completed online certifications from Harvard University. She has authored two research articles namely, Mustard Dhara – An exploration of legal and regulatory aspects in the agricultural sector and Surrogacy in India: Comparative Analysis with Global Legal Trends (coauthored with Akshita Garg) – Published in IJLLR.
